Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Category Archives: Regtech, Compliance, Governance
Canada Open Banking Commercialization Roadmap
Open Banking in Canada | Nov 26, 2025
Revenue Opportunities For Canada's Consumer Driven Banking Act
Canada is moving into a new phase of financial services with the Consumer Driven Banking Act. Budget 2025 confirms that open banking is officially moving forward, with a clear sequence for how the system rolls out. Legislation and technical standards in focus throughout 2025. The Bank of Canada receives new funding to supervise Canada's Open Banking Framework, and the government commits that people will not face fees when they access or share their financial data. The Real Time Rail to be launched in Q3 2026. Full open banking functionality including payment initiation is expected by mid 2027.
See: Canada’s Open Banking Journey: Interview with Huw Davies, Chief Commercial Officer OZONE API (UK)
People will soon gain the right to share their financial data safely, securely and at no cost with accredited providers (which is highly important given the JPMorgan data fee backlash in the US). This functionality creates room for new products and new revenue models. It also pushes banks, fintechs and API platforms to rethink how they plan to commercialize the framework and grow. Since providers cannot charge fees for in scope data, the value sits in the tools and services built on top of that shared information.
Huw Davies puts useful ideas on the table in a recent Ozone API article, 'show me the money' about treating open banking APIs as real commercial channels. His thinking sparks a closer look at how those ideas land in Canada, where the rules, accreditation structure and staged rollout create a different set of opportunities. When you look at the Consumer Driven Banking Act through a commercial lens, the roadmap becomes clear. This article provides an overview of some models that could work in the read only phase. Other models unlock once write access arrives in phase 2, and a few ideas won't fit the Canadian framework at all.
What Models Work With Read Only Open Banking
Open banking in Canada begins with safe, consented data access, but the first year focuses on building the foundation rather than running a live system. Through 2025, the government works on legislation, technical standards, accreditation, supervision and security. The Bank of Canada receives $19.3 million over two years to lead this work, and the government redirects $36.9 million previously assigned to the Financial Consumer Agency of Canada to support the transition. Cybersecurity receives new funding as well, including $25.7 million over five years and an ongoing $5 million allocation for CSIS and the RCMP.
See: UK Open Banking Update and Road to Open Finance
Read only data-sharing is expected to take shape in 2026 once the technical and operational framework is ready. In this stage, accredited providers can only read in scope data that a person approves. They cannot trigger payments or update any accounts. Revenue can be generated from insight, identity, developer experience and onboarding support. These components create value without charging for the data itself. Below is an overview of some models that can work during the read only stage.
Phase One Commercial Opportunities
| Type | Model | Viability | Why It Works | How It Generates Revenue |
| Enrichment and Analytics | Categorization and personal finance tools | High | Turns raw data into clear insight for users | Subscriptions or bank partnerships |
| Small business cash flow dashboards | High | Helps business owners manage money and plan ahead | SaaS pricing | |
| Spending and savings insights | High | Gives people visibility and confidence | Consumer upgrades | |
| Identity and Compliance | Identity verification and KYC | High | Accreditation increases demand for strong identity tools | Per verification fees |
| Fraud detection and risk scoring | High | Supports trust across the ecosystem | Event based fees | |
| Consent and audit logging | High | Helps accredited providers meet compliance requirements | Platform fees | |
| API Performance | High throughput tiers | High | Monetizes reliability and speed instead of raw data | Tiered usage |
| Extended transaction history | Moderate | Depends on regulatory interpretation | Premium tier | |
| Enhanced sandbox and developer tools | Moderate | Developers value better testing environments | Developer subscriptions | |
| Acquisition Flow | Data driven onboarding | High | Improves conversion and lowers friction | Better product economics |
| Account comparison and switching | High | Read access supports more transparent experiences | Customer acquisition gains |
The early phase rewards companies that help users understand their financial picture, help institutions manage compliance and help developers work with clean, reliable data. These models feel simple on the surface, but they will create the foundation for the expanded market activity that follows in phase 2. They also align fully with the principle that in scope data must be free for users.
What Opens Up When Canada Activates Write Access
Write access becomes possible once the Real Time Rail operates across Canada. Budget 2025 confirms that the RTR is expected to become operational in Q3 2026, and as a result, full consumer functionality under open banking, including payment initiation, is expected by mid 2027. This next phase turns open banking into a high value service layer, where accredited third parties can initiate transactions, open accounts, trigger lending and handle real time flows with user permission.
See: BoE Report: Open Banking Boosts Productivity, Competition
This stage unlocks the commercial engine most people associate with open banking. Money moves. Accounts open. Platforms become financial channels. Merchants cut payment costs. Developers build financial workflows inside the tools people already use.
Phase Two Commercial Opportunities
| Type | Model | Viability | Why It Works | Revenue Trigger |
| Payments | Payment initiation for merchants | Very High | Direct bank payments reduce card fees and settlement time | Per payment fees |
| Invoice and bill settlement tools |
High |
Helps small businesses streamline payment operations | Transaction fees | |
| Embedded Credit | Loan origination APIs | Very High | Supports real time underwriting with live data | Origination fees and credit margin |
| Short term credit or BNPL tools | High | Easily integrates into digital journeys | Revenue share | |
| Modular Banking | Deposit account creation | High | Platforms control user experience while banks manage account infrastructure | Per account fees and float |
| Card issuance APIs | High | Works well for vertical software platforms | Interchange share | |
| Onboarding flows and identity orchestration | High | Smooth onboarding drives product adoption | Per onboarded user | |
| SME and Enterprise Services | Treasury and cash management | High | Real time rails enable automation and control | Subscription and volume fees |
| Payroll linked payments | Moderate | Depends on broader ecosystem readiness | API usage fees |
This is the phase where open banking becomes a full commercial channel where many parts of the value chain becomes programmable.
- Payment initiation reduces merchant costs
- Embedded credit improves access to financing
- Modular banking empowers platforms to offer financial products without becoming banks (a platform can add things like accounts, cards or payments as simple API components instead of building full banking infrastructure)
- Real-time treasury services help small and medium sized businesses manage operations
See: Canada’s Open Banking Journey: Interview with EY’s Dr. Francesco Pisani and Dr. Alexander Christoph
The companies that build trust, reliability and encourage developer adoption during the read-only phase will enter this phase with a strong advantage.
What Does Not Fit Canada’s Open Banking Framework
Canada's open banking rules are set to ensure people have the right to access and share their financial data without paying fees. So certain business models do not align with these requirements. If a model creates barriers or charges for in scope data, it won't fit in the current framework.
Low Viability Models
| Model Type | Viability | Why It Fails In Canada |
| Charging consumers for access to their own data | Very Low | Conflicts with the rule that in scope data must be free |
| Charging fintechs for raw data | Low | Creates unfair access for smaller players |
| Per call pricing for basic data | Low | Undermines competition and equal participation |
| Proprietary or closed APIs | Low | Goes against interoperability requirements |
| Monetizing derived data without clear consent | Low | Creates privacy and liability risk |
| Charging fintechs for mandated data access | Low | Conflicts with the goals of the framework |
Canada wants an open and competitive ecosystem that rewards companies for the value they create, not the data they gate. If a business model depends on tolls, walls or restrictions, it sits outside of Canada’s open banking structure.
Outlook
Budget 2025 sets a clear timeline and path towards open banking commercialization. Standards and supervision take shape in 2025. The Real Time Rail becomes operational in 2026. Full functionality arrives in 2027. Phase one rewards companies that focus on insight, identity, compliance and developer experience. Phase two rewards companies that plan for payments, embedded credit, modular banking and real time financial workflows. Some models won't work as they conflict with the rules of the framework.
See: Take Part in the Global AI in Finance 2030 Survey
While it took Canada half a decade to get here, it's approach to Consumer Driven Banking balances innovation with protection. The phased rollout also encourages companies to build strong foundations early and to prepare for the more substantial opportunities when write access arrives. The organizations that engage with phase one now will be in the strongest position once the full system becomes available.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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SEC Clears Fuse Token In New Crypto Decision
Crypto Regulation | Nov 25, 2025
AI generated image
A New Reference Point for Behaviour-based Token Design
On November 24 2025, the US Securities and Exchange Commission (SEC) Corporate Finance Division issued a no action letter to Fuse Crypto Limited that sets the conditions under which the company can offer its ENERGY token without triggering US securities registration under Section 5 or reporting requirements under Section 12(g). This action gives the market a detailed example of how a behaviour based reward token can satisfy regulators when the program avoids speculation and ties all earning activity to user actions.
What The SEC Reviewed And The Conditions Behind Its Relief
The SEC based its position on the facts described in the request for relief letter that Fuse’s counsel submitted on November 19 2025 (13 page PDF). The filing outlines how the program works how users earn tokens and how redemption value is controlled. The SEC makes clear that any different facts or conditions could lead to a different conclusion.
Fuse’s submission describes a program that rewards users for energy related behaviour that supports distributed energy resources. Users earn tokens when they install and connect rooftop solar systems, batteries, electric vehicle chargers or similar equipment. They also earn tokens when they make this equipment available for grid supportive functions or adjust consumption to help reduce stress on local systems. These actions are measurable and tied directly to the program.
See: Coinbase Opens a New Chapter for Token Sales
The submission explains the formula Fuse uses to allocate token rewards. The formula measures user generated energy behaviour and applies a fixed structure that determines the number of tokens a user receives. This formula must remain constant. The SEC notes that it depends on this structure when evaluating whether the program’s value creation resembles investment activity.
The filing also states that redemption value is capped. Users may redeem tokens only for goods or services the program makes available at the time of redemption. The value cannot exceed Fuse’s profit margin and redemption depends on average market pricing. This removes speculative upside and keeps the token tied to consumption.
The submission also details that Fuse will present the program as a rewards system and not as an investment, and that all earning activity must flow from how users participate in the program. Users configure their preferences inside the app to enable token earning and select the settings that determine how their connected energy resources take part in the program. The filing states that token rewards come only from this participation and from measurable energy related behaviour, and that all value remains tied to capped redemption and consumptive use rather than to any form of investment activity.
The program does not give token holders any right to profit sharing future income ownership or governance. All value comes from user behaviour and redemption inside the program.
See: Are Your Tokens Securities? New EU Rules Say Maybe
These conditions help regulators understand that the token does not function like a security. The SEC confirms that its relief applies only to these facts and does not classify the token.
How The Program Works
The Fuse program connects token creation to real actions that support distributed energy systems. Users earn tokens directly from participation and do not buy them with investment expectation. The structure ties value to measurable behaviour and redemption uses a strict cap based on profit margin and market pricing. This design prevents investor style appreciation and aligns the token with its use as a reward.
This event gives issuers a detailed reference for designing behaviour based programs. Many token projects claim utility status but still allow value growth that resembles investment behaviour. Fuse provides an example of how limits on value, transparent formulas, and consumption use can support compliance.
The program also shows that clear documentation matters. Fuse’s submission provides detailed explanations of user actions, redemption rules, promotional commitments, and technical configuration.
Regulators rely on this specificity when evaluating whether a token program functions as a financial product. Fintech teams building similar programs can use this model to see how clear rules and measurable user actions help regulators understand how the system works.
Can This Work in Canada?
The SEC decision gives Canadian fintechs a good example of how American regulators analyze behaviour-based token programs. Canadian regulators continue to rely on the economic reality approach as set out in the CSA staff notice 46-308 on token classification published June 11 2018. While no formal newer guidance appears to have been issued publicly, issuers should monitor for any updates.
This guidance explains that labels do not determine the legal outcome. Regulators examine the purpose of a token how it enters circulation how users receive value and whether promotional language creates investment expectation.
See: Quebec Decision Challenges Canada’s Crypto Rules
The Fuse no action letter and submission model aligns with these principles. It shows how programs that tie value to specific actions and use measurable formulas can reduce regulatory risk. Canadian issuers designing clean energy mobility or infrastructure incentives can benefit from reviewing the program and understanding how to document participation value mechanics and redemption paths in a compliant manner.
Many Canadian fintechs build products that operate in both markets. The SEC decision provides a reference for how US regulators evaluate tokenized reward-based systems. Canadian teams could use the US-based Fuse decision to prepare materials that align with principles used in both countries.
What Could Still Change And Why The Relief Is Conditional
The No Action Letter applies only to the facts Fuse described in its incoming letter. If Fuse changes earning mechanics, redemption formulas, user eligibility, promotional language, or transferability rules the SEC may reach a different conclusion. The relief applies only to Section 5 and Section 12(g) and does not bind other regulators. The No Action Letter also doesn't prevent actions by other divisions inside the SEC or by other agencies such as the CFTC, FinCEN, IRS or state regulators.
Canadian regulators may also reach a different outcome if facts differ from the submission or if market behaviour creates investor style expectations. The SEC’s letter does not classify the token. It only describes the enforcement position for the facts presented.
Conclusion
The SEC's corporate finance decision on the Fuse reward program gives fintechs a detailed look at how behaviour based tokens can meet regulatory expectations when value comes from measurable user actions and redemption is tightly controlled.
See: The Role of a Crypto Wallet in Canada’s Digital Finance Future
Canadian fintechs designing cross-border token programs can use the Fuse no action event to help design programs and prepare materials that address the economic reality tests used in Canada. As more companies explore real world token models this type of clarity supports innovation and helps developers understand how to design programs that balance consumer incentives with regulatory confidence.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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How Fintech Teams Move From Tools To Agents
AI Productivity | Nov 25, 2025
Managing Hybrid AI Teams For Stronger Performance
A founder at a Canadian fintech reviewed a routine workflow and noticed something important. The company had recently replaced several older tools with newer AI powered systems, and remarkably the new configuration could complete multi step tasks that used to require manual effort. The system gathered information, applied rules and moved the case forward without constant human prompts. Nothing unexpected happened. The work simply flowed from step to step. In that moment the team recognized that they were no longer working with simple tools. They had introduced capabilities that belonged in the agent category, even if no one had used that word yet.
See: Should Fintechs Design for People or AI Agents?
The realization opened a larger conversation inside the company. That is the new AI systems didn't behave like single purpose tools like before. They behave more like assistants that can move through a workflow once they understand the goal. The team had not changed the work. The technology had changed what the work could look like, and recent research confirmed this realty of how teams are coordinating autonomous systems across full processes.
Understanding the Difference Between A Tool And An Agent
A tool performs a single action only when prompted. It behaves like a calculator or a search bar. Tasks such as summarizing documents, extracting fields, drafting support replies or classifying transactions remain inside this zone. A person decides each step. The system never chooses what to do next.
An agent behaves differently. It acts. It moves through a journey, maintains context, decides the next step and continues until it reaches a point where it needs help or completes the goal. Take a look at these AI use cases by haptik, such as CASHe credit flow where a conversational system guides a borrower from authentication to instant approval, or how Zuri improves efficiency and customer experience at Global insurance leader Zurich without human involvement. Both examples highlight AI agent behaviour, and not tools.
The practical 'acid test' for fintech teams is simple. Ask who chooses the next step in the workflow. If the human chooses, it remains a tool. If the system decides, it behaves as an agent. This distinction matters because agents require supervision, governance and ownership. They influence outcomes and customer experience. Treating an agent as a tool leads to blind spots.
See: Which Fintech Processes Are Most Ready for Agentic AI
Evidence from global surveys explains why this distinction matters for performance. The findings on workplace AI usage show that 88% of employees use AI at work but only 5% use it in ways that change their roles. Organizations also lose more than 40% of potential productivity gains (opportunity cost) when talent, workflows and governance do not align with the technology.
When fintech leaders understand the moment when tools become agents, they gain the vision needed to build high performing hybrid teams.
How AI Agents Change Daily Work In Fintech
Once a fintech organization recognizes that its systems behave like agents, the nature of work begins to change. People no longer complete tasks in isolation. They supervise agents that perform sequences. The work becomes a blend of human judgement and systems execution. See this research on end-to-end agentic workflows, which analyzes how a few people can guide a large number of agents across full processes. These supervisors focus on results rather than steps. They correct behaviour, interpret outputs and refine the system. The work becomes less about completing tasks and more about guiding outcomes.
Check out this practical example describing an agentic fraud systems showing how agents monitor transactions, test controls and highlight anomalies. Human analysts review these exceptions, approve responses and explain logic to regulators. The agent carries out the first layer of work. Humans perform higher judgement. This structure changes daily routines.
A hybrid team begins the day by reviewing the agent log. They scan escalations, exceptions, unexpected patterns and customer interactions. The team also discusses where the agent needs correction, where it performed well and where rules need refinement. This daily rhythm feels closer to coaching a junior colleague than running a piece of software.
See: Breaking Canada’s Productivity Trap For Stronger Growth
Changing structural workflows and shifting from doing to supervising can have cultural effects. Some feel replaced while others feel empowered. Leadership determines the direction.
When leaders explain that supervising agents is a higher judgement role, employees view it as progression. When leaders fail to explain, they view it as displacement.
5 Insights to Manage High Performing Hybrid Teams
Managing hybrid teams requires clarity, structure and shared visibility. A hybrid team succeeds when the agent behaves predictably, the humans supervise confidently and both sides contribute to results.
1. Ownership
When no one owns the behaviour of an agent, the system drifts. Fintech leaders need to assign a small group of people to own a journey end to end. Strong supervision with the authority to adjust prompts, thresholds and workflow logic.
2. Transparency
Every action taken by an agent must appear in a shared log. Without this, the team can't diagnose issues or maintain trust. The shared log becomes the anchor of the hybrid team.
See: Canada’s Fintech and AI Firms Lead Deloitte’s 2025 Fast 50
When a human intervenes, the reason appears in the same log. When an agent acts, the outcome appears there as well. This shared view prevents confusion.
3. Refinement
Teams must review the agent’s behaviour frequently. The review cycles in studies of agentic processes show that continuous improvement drives results. In practice, teams meet weekly to adjust rules, refine decision boundaries and align the agent with policy. These refinements keep the system current and adaptive.
4. Human Override
Agents cannot handle every scenario. Hybrid teams need clear rules for human intervention. They must know when to stop the agent and how to redirect it. Regulatory environments require this clarity. Fintech companies that operate in regulated sectors must explain why the agent acted and when a human stepped in.
5. Measurement
Leaders need to measure the hybrid team as one unit. The work of the humans and the work of the agent form one system. Outcomes such as customer satisfaction, approval speed, fraud reduction and error rates reflect joint performance. When both sides improve together, results accelerate.
Hybrid teams succeed when leaders treat the agent as a teammate with responsibilities and supervision rather than as a simple tool or gadget.
Why Hybrid Teams Matter
Canadian fintech companies operate inside a competitive global environment. Research from major international surveys positions AI as critical infrastructure for financial systems. Productivity gains increasingly come from the interaction between humans and agents rather than from models alone.
Read: AI’s Hidden Costs in Replacing Junior Workers
Tools help people work. Agents help the company run. Those that treat AI only as a set of single purpose tools are at risk of falling behind. Fintech leaders who understand this difference, and who build hybrid teams around it, will gain an advantage in scale, efficiency, and risk management. They also build trust with regulators and partners. A company that can explain how its agents behave, why they behave that way and how humans supervise them will become a more reliable and stronger participant.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Fintech and Canada’s Updated Rules for Environmental Claims
Greeneashing Rules | Nov 24, 2025
Canada Updates Greenwashing Rules and What Fintechs Need To Know
On November 18 2025 the federal government introduced proposed changes to Canada’s environmental claim and greenwashing rules through Bill C-15, building on the November 4 2025 federal Budget. These proposals respond to concerns from businesses that the original 2024 framework increased uncertainty and cost. For financial technology firms that use climate related data or sustainability linked claims, these adjustments have important implications.
What The Original Regime Introduced
The original greenwashing provisions came into force through Bill C-59, which received royal assent on June 20 2024. See NCFA's fintech focused overview of the original green claim rules.
When the Competition Bureau released the June 2025 environmental claims guidance, firms received clearer detail on what regulators expected for forward looking climate statements, evidence standards and internal documentation. Even with that guidance, companies found the requirements strict and often unclear, particularly around which international standards qualified.
Why and What Changes Under Bill C-15
Bill C-15 proposes to adjust parts of the greenwashing rules that came into force in 2024. The government introduced these changes because many companies, including financial institutions, said the original rules were too unclear and made it difficult to speak openly about their environmental plans.
Bill C-15 responds to those concerns by removing the requirement that business level environmental claims must follow an internationally recognized methodology, which was one of the main sources of confusion. Businesses would still need evidence to support any environmental claim they make but they can focus on internal logic and documented methods.
See: Rising AI Energy Use: A Call for Sustainable Innovation
Bill C-15 also proposes to change how greenwashing complaints are handled. Under the rules introduced in 2024, private parties such as advocacy groups, competitors or individuals can file applications directly with the Competition Tribunal for business environmental claims. This direct access was part of broader competition law reforms and became a significant concern for companies. Bill C-15 would remove that direct pathway and require private parties to bring their concerns to the Competition Bureau instead. The Bureau would then decide whether a case should proceed. The government introduced this change because many firms said the threat of direct Tribunal applications increased uncertainty and could discourage them from sharing legitimate climate related information.
The proposed changes aims to preserve protections against misleading claims while reducing the risk of unnecessary or strategic litigation.
Comparison Before and After the Changes
| Consideration | Original 2024 Rules | Updated 2025 Rules (Bill C-15) | What This Means For Fintechs |
| How Environmental Claims Are Justified | Required adequate testing and alignment with an internationally recognized methodology | Requires substantiation but allows firms to use documented internal methods | More flexibility in climate data modelling, ESG scoring and analytics tools |
| Interpretation Burden | High. Firms struggled to interpret which global frameworks counted | Lower. Evidence judged on internal consistency | Clearer expectations reduce risk of misinterpretation |
| Documentation Expectations | Documentation needed to show alignment with international frameworks | Firms must document data sources and assumptions but no external alignment is required | Focus on internal logic and auditability |
| Future Oriented Climate Claims | Long term claims required alignment to global pathways | Claims still require evidence but internal pathways may be used | Forecasts need realistic milestones rather than matching global models |
| Risk of Challenge | Higher due to methodology disputes | Lower for methodology disputes but misleading advertising rules still apply | Risk shifts toward evidence quality |
| Enforcement Pathway | Private parties could bring cases to the Tribunal | Complaints routed through the Competition Bureau | Fewer activist driven cases but oversight continues |
| Practical Impact on Companies | Some firms paused climate commitments due to uncertainty | More predictable expectations support climate initiatives | More predictable environment for climate product development |
| Compliance Costs | Higher due to ambiguity around methodology | Moderate. Costs remain but ambiguity decreases | Less need for external validation. More need for strong internal controls |
| Innovation and Competitiveness | Rigid framework slowed innovation | Flexible system encourages innovation | Fintechs gain room to differentiate through credibility |
| Investor Signal | Uncertainty signalled regulatory volatility | Clear expectations reduce perceived friction | Fintechs become more attractive to investors |
Fintech Implications
Claim Support And Data Systems
Fintech firms need strong and reliable data infrastructure to support any environmental claims made in their products or services. While the updated rules remove the pressure to match a specific international framework, but they do not lower the expectation for clear evidence. Fintechs must be able to show how their data is collected, how their models work and why their outputs are reasonable.
See: Green Fintech 2.0 Shows Progress in the UK
Internal logic, consistency and transparent documentation matter more than ever because the assessment standard focuses on whether a claim can be substantiated using the firm’s own methods. This means the credibility of a fintech product depends heavily on the quality of its data foundations and (environmental) claims.
Future Climate Commitments Also Carry Risk
Any statement about future emissions, climate pathways or long term environmental outcomes requires realistic modelling and measurable steps.
This risk was highlighted when the Royal Bank of Canada pulled back its sustainable finance commitment after saying it could not confidently measure progress under the current rules.
Fintech tools that produce projections, risk curves or carbon estimates must demonstrate how the assumptions behind those outputs were chosen and how progress will be tracked. Future oriented claims remain high risk unless methods, milestones and supporting records are clear.
Compliance Costs And Competitive Positioning
The updated framework may reduce the cost that came from interpreting international standards, but meaningful compliance work remains. Fintechs still need controlled data environments, version tracking, testing protocols and maintained audit trails.
Read: Sustainability: A Must for Fintech Growth
Firms that use verification as a core part of product design can position themselves ahead of competitors because customers and investors will expect transparency in climate related data. Strong internal controls also help firms defend claims if they are questioned by regulators or partners.
Risk Remains, Gatekeeper Pathway Changes
Removing direct access to the Competition Tribunal lowers the chance of activist driven cases, but environmental claims will continue to be reviewed under misleading advertising rules.
The Competition Bureau remains the main decision maker and it can act where evidence is weak or claims are overstated. For fintechs this means that scrutiny continues but will be more predictable and clearer process. Firms should expect oversight to focus on accuracy and evidence rather than whether a specific global methodology was used.
Priorities For Fintechs Right Now
Fintech teams should review the environmental claims used in products, marketing or investor materials and ensure the evidence behind those claims is complete and easy to explain.
Internal methodologies should be clear so product, compliance and technical teams can show how calculations and scores are produced. Future oriented statements need documented assumptions, milestones and data sources.
See: AI Energy Score Ratings A Step Towards Transparency in AI
Firms should also monitor the progress of Bill C-15 and upcoming Competition Bureau guidance so they can adjust their documentation and product practices as expectations evolve.
Why This Matters
Environmental credibility impacts how investors and partners evaluate opportunities in sustainable finance and climate technology ventures. The updated rules aim to keep protections against misleading claims while reducing uncertainty that can slow down innovation. Fintechs that build strong and transparent verification systems can strengthen their competitive position, support customer confidence and contribute to a more trusted and transparent sustainable finance ecosystem in Canada.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Canada Releases The First Draft Of The Stablecoin Act
Stablecoin Regulation | Nov 21, 2025
Image generated by AI
Canada’s Draft Stablecoin Act Inside Bill C 15 Now Sets Out Concrete Rules
On November 18 2025, the federal government of Canada released its first draft of the Stablecoin Act when introducing the Budget 2025 Implementation Act through Bill C 15. The legislation appears in Division 45 of Part 5 and establishes Canada’s first national framework for stablecoins. The official text published in the Bill C 15 First Reading record explains that the Act sets duties for stablecoin issuers, outlines the role of the Bank of Canada and introduces rules for reserves, redemption and governance. The full clause-by-clause level rules appear in the Draft Stablecoin Act document, now moved to a dedicated page on the Department of Finance's website under Canada's Stablecoin Framework.
How Stablecoins Fit Into Canadian Law
The Act explains that if a company issues a stablecoin and follows this new federal law, the company is not treated like a bank for certain parts of the Bank Act, the Insurance Companies Act or the Trust and Loan Companies Act. In simple terms, if a company issues a stablecoin under this law, it is not treated as if it is taking deposits like a bank. This helps make sure that stablecoin issuers are regulated, but not in a way that turns them into banks.
See: Bank of England Sets New Rules for Systemic Stablecoins
The draft Act also says that if a company issues a stablecoin and follows this law, it is not treated as if it is dealing in securities for the specific federal rules listed in the Act.
Clear Duties for Stablecoin Issuers
The Act gives the Bank of Canada the job of keeping a public list of approved stablecoin issuers. An issuer must not give false or misleading information to the public.
The Act also places limits on what issuers are allowed to do. An issuer cannot use regulated words or symbols in a way that breaks future rules. An issuer cannot pay interest or any form of yield to stablecoin holders. This means stablecoins covered by this Act cannot look or act like investment products.
The Act also says an issuer cannot offer a stablecoin if it is treated as official money anywhere in the world. The issuer cannot offer a stablecoin if it is viewed as a bank deposit, if it is insured by a government deposit insurance program or if it is guaranteed by a government.
Reserves, Safety and How Customer Money Is Protected
The Act has strong rules for how issuers must hold reserves. An issuer must hold enough assets to match the full value of all stablecoins in circulation. These assets can only be used to redeem stablecoins. They cannot be used for anything else.
The reserve must consist of the same currency the stablecoin is tied to or high quality liquid assets in that currency. Only the Bank of Canada or future regulations can approve other reserve assets.
See: Quantum Safe Stablecoins Meet Real Time Finance Needs
The Act protects these reserves from being pledged, used as collateral, or borrowed against. The issuer cannot let anyone else have a claim on them.
The issuer must keep reserve assets with qualified custodians. The custodian must hold these assets separately from their own. The assets must not be available to satisfy the debts of the custodian or the issuer. They exist only to support redemptions. This helps keep customer value safe even if something goes wrong with the issuer or the custodian.
Redemption Rights for Stablecoin Holders
The Act makes clear that stablecoins must be redeemable at face value in the official currency they track. The issuer must follow this rule in line with future regulations. This protects users who want to convert stablecoins back into regular money.
Issuer Governance and Oversight
Issuers must have a governance policy that sets out who is responsible for what. This includes the responsibilities of the governing body and senior management, how accountability works, how third party service providers are managed and how conflicts of interest are handled. This pushes issuers to run stablecoin operations with clear oversight and internal controls.
Securities, Deposits and Anti Money Laundering
The Act explains where stablecoins fit into the wider regulatory world. A compliant stablecoin issuer is not considered to be dealing in securities or taking deposits for certain sections of federal prudential laws.
The Act also says that a stablecoin issuer counts as a business dealing in virtual currency under Canada’s anti-money laundering and anti-terrorist financing laws. This means the issuer must follow all federal AML and ATF rules, just like any other virtual currency business.
Outlook
The draft Act must still move through Parliament. Many details will depend on future regulations written by the Minister and guidance from the Bank of Canada. Provinces will continue to have their own rules, including securities and consumer protection laws. The restriction on interest and yield pushes stablecoins towards payment and settlement functionality rather than investment use. The reserve and custody rules help protect customers. The governance requirements ensure that issuers treat stablecoins as serious financial products with clear oversight.
See: Stablecoin Insights From FCAC’s 2025 National Survey
This draft law provides clear rules on reserves, custody, redemption and governance. It also clarifies how stablecoins fit within Canadian financial law, which helps fintechs design products, build payment systems and plan compliance with confidence. Earlier this year in July 2025, EY published a report on various approaches to global stablecoin regulation
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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OSC $30K Research Grants for Ontario’s Capital Markets
Regulation | Nov 21, 2025
Image: Freepik/jannoon028
OSC Research Grant Competition Opens With Focus On Market Competitiveness
On November 19, 2025, the Ontario Securities Commission announced the launch of its Research Grant Competition. This is a pilot initiative that provides up to five (5) grants of $30,000 each to support research on the competitiveness of Ontario capital markets.
See: Breaking Canada’s Productivity Trap For Stronger Growth
The purpose of the competition is to invite proposals from researchers to examine how Ontario capital markets can stay efficient, innovative, and globally competitive as outlined in the Competition Details.
Eligibility And Award Details
The program is open only to researchers who work at or are enrolled in a Canadian academic institution and who have not been employees or directors of the OSC during the past five years. Applicants must also confirm that they aren't involved in any unresolved regulatory or criminal findings. The OSC will award up to five grants of thirty thousand dollars with submissions due February 27 2026, winners notified April 17 2026, and final papers due August 14 2026.
Grant Vingoe, CEO of the OSC:
“The OSC Research Grant Competition is seeking to tap into Canada’s brightest minds to undertake the challenge of delving into the competitiveness of Ontario’s capital markets. In light of the current global geopolitical and economic challenges, it is increasingly important that we look at ways to help Ontario’s capital markets remain competitive, and we welcome the fresh thinking that the competition will bring, as we look ahead and plan future initiatives.”
Selection Criteria And Publication
The OSC will review proposals based on alignment with its mandate, originality, feasibility, academic support, and public benefit. Successful researchers will have their papers published on the OSC website and may present findings directly to senior leadership.
Wider Participation Could Add Value
The competition currently limits eligibility to academic researchers. Wider participation from industry experts, innovators, and market practitioners could provide applied evidence on real operational friction such as registration, compliance, cost, access to capital, and technology adoption.
See: Innovative Approaches to Smarter Regulation
Numerous experienced practitioners who work on the front line encounter daily competitive pressures and could offer insights that complement academic analysis but unfortunately grant funding appears tied to researchers in academia.
Why This Matters
Ensuring Ontario's capital markets remain competitive plays a key role in Canada's economic strength. While the research supported by this OSC initiative could influence future policy decisions related to capital formation, market structure, and investor confidence, if the goal is truly to benefit Ontario's capita markets one wonders why participation is restricted to researchers. The bottom line is that whatever insights are produced, if the OSC is to implement any of the ideas into practice it must be done swiftly, especially insights that help identify (quantify) structural barriers that affect the ability of Canadian firms to grow and compete globally.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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Breaking Canada’s Productivity Trap For Stronger Growth
Bank of Canada | Speech | Nov 20, 2025
Image: OECD via Haver Analytics and Bank of Canada 2023
Bank of Canada Calls For Action To Fix Canada’s Productivity
On November 19 2025, the Bank of Canada (BoC) released a speech, 'Toward a virtuous circle for productivity' delivered by Nicolas Vincent the external Deputy Governor at a recent event of the Association des économistes québécois (ASDEQ) together with CFA Québec.
See: BoC’s Carolyn Rogers Calls Banks an Oligopoly
His talk explains the pattern of Canada's long standing productivity challenges and sets out what needs to change. Canada has lived with the same productivity problem for a generation. Growth has slowed, investment has weakened, and the country has become more exposed to global shocks.
Key Takeaways
Weak productivity discourages investment, and weak investment keeps productivity low.
Regulatory and competitive conditions are central to improving that pattern.
Training, mobility, and credential recognition must work better to support new technology.
- Status quo isn't acceptable as keeping the current environment in place would lock in today’s slow growth.
Vincent captures the situation clear:
“To put it bluntly, we’re stuck in a vicious circle.”
He notes that productivity grew about 3% in the 1960s and 1970s but fell to roughly 1% between 2000 and 2019. When productivity is weak, wage gains soften and demand becomes fragile. Then companies hesitate to invest in new tools or equipment, and that hesitation feeds right back into weaker productivity.
He highlights 3 things that need to change the trajectory (not a quick fix)
1. Strengthening The Investment Environment
The investment climate is paramount for firms trying to modernize. One of the clearest lines in his speech addresses the barrier businesses often describe:
“Businesses often tell us that Canada’s regulatory framework is too cumbersome, complex and far-reaching.”
A stronger investment climate means faster decisions, clearer expectations, and fewer overlapping rules. That allows companies to move ahead with projects that raise productivity instead of delaying them.
See: Why AI Investment Is Missing What Workers Actually Want
In fintech, it's especially important because licensing decisions, compliance approvals, and inter-provincial regulatory alignment determine how quickly a firm can launch or scale. When these pathways work well, investment grows and innovation accelerates.
The opposite has been visible for a decade (at least). Companies often face unpredictable pathways, uneven timelines, and unclear requirements (think the original equity crowdfunding rules, open banking, payment modernization etc). Those conditions slow product launches, and discourage upgrades. They also weaken the broader economy by delaying the investment (both internal and external) needed to lift productivity.
2. Promoting More Competitive and Dynamic Markets
Vincent says competition pushes companies to improve and become more resilient:
“Canadian businesses that are highly exposed to international competition evolve and improve. This makes them more productive, competitive and resilient.”
Competitive markets encourage businesses to adopt better technology, strengthen processes, and serve customers more effectively. This raises productivity across entire sectors.
See: Competition Bureau Consultation: New Enforcement Guidelines
When competitive pressure is limited, firms face fewer reasons to upgrade or innovate quickly. That is the opposite of what a modern economy needs. Slower adoption means slower productivity gains, and slower gains leave the economy more exposed to global changes.
Leaving competition conditions unchanged would keep the loop intact and make it more difficult for Canada to close its gap with peer countries.
3. Investing In Skills, Mobility And Talent
Vincent points out that productivity depends on people as much as on technology:
“Investing in our talent … means making it easier to recognize professional accreditations across provinces and territories, and the foreign credentials of people who move to Canada.”
Training systems that adapt quickly, credential pathways that work smoothly, and mobility across provinces all help firms adopt new technology with confidence.
See: What Gen Z and Millennials Expect From Fintech
Today’s reality is different. Workers often wait months or years to have skills recognized, training programs lag behind new tools, and mobility rules slow the movement of talent. These conditions limit how quickly firms can scale, modernize, or respond to new opportunities.
Keeping this in place would weaken the very foundation needed for stronger productivity.
Productivity Gains Are Essential For Canada’s Future
Vincent’s message is measured but urgent. Canada's productivity problem is caused by multiple things, and no single fix. But the government policies that impact investment, competition, and talent development must work better than they do today. These are public frameworks that governments influence, and businesses must act on them once conditions improve.
The payoff is substantial and what all Canadians should be aiming for. Higher productivity strengthens incomes, supports wage growth without inflation pressure, expands competitiveness, and improves resilience in a world where shocks are becoming more common.
See: Fintech’s Role in Canada’s Productivity Revival
The status quo of slow investment, limited competition, and restricted talent must be changed to improve the the country’s economic strength and provide opportunities for Canadians to build a stronger future.
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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